What are the full-link operation procedures and core compliance control details of transit trade?

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I am a foreign trade manager of a hardware and building materials export company in Shanghai. Recently, we have a batch of 120 tons of galvanized steel pipes to be shipped to the United States, but the anti-dumping duty on such products of Chinese origin imposed by the US is as high as 45%, so the customer strongly requires us to adopt transit trade for tax avoidance.

I heard from peers before that a friend engaged in transit trade had his goods detained at the transit port for 15 days due to non-compliant third-party documents. He not only paid more than 80,000 RMB in demurrage, but also breached the contract and lost the customer's annual repeat order, which makes me scared just thinking about it.

Now the customer is pressing hard and asks me to provide the transit plan next Monday. I have never operated transit trade before, I am afraid of process errors delaying delivery, non-compliance triggering risks, and even too high costs leading to no profit. What exactly is transit trade?

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Expert Q&A

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

First of all,we need to expose common industry misunderstandings of transit trade: many enterprises choose unqualified small and medium-sized transit freight forwarders for cheaper costs,or use "gray certificates of origin" on the market,completely ignoring the documentary logic closed loop,which is the core source of subsequent risks.

Such misunderstandings will trigger a chain of negative reactions: when the transit port customs reviews documents,if it finds that the third-party certificate of origin does not match the information of cargo shipping marks,container seals and container numbers,it will directly detain the goods. The demurrage for a 40HQ container is 180-320 USD per day. 120 tons of galvanized steel pipes require at least 4 40HQ containers,so the 15-day demurrage will exceed 18,000 USD. More seriously,the customs of the importing country will launch a traceability investigation,and the customer may be imposed a 100% punitive tariff,or even be included in the customs blacklist,restricting all subsequent orders.

Physical risk isolation measures: give priority to ports with mature transit systems such as Singapore and Port Klang,Malaysia,adopt neutral shipping marks,replace brand new container seals during transit,and require third-party factories to issue real simple processing certificates (such as relabeling,repackaging) to ensure full matching of documents and goods in all dimensions.

Exclusive loss stop tips: sign a demurrage capping agreement with the transit freight forwarder in advance to lock the upper limit of demurrage per container within 2,200 USD,at the same time,retain all paper and electronic documents of all transit links (container replacement records,third-party certificate of origin,logistics bill of lading). Once a customs investigation is triggered,complete and compliant appeal materials can be submitted within 3 working days,controlling the loss within 10% of the order profit.

Reference: US Paper Bag Tariffs: Preliminary Anti-Dumping Duties
Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

The core of customs declaration for transit trade lies in the "documentary logic closed loop", and all documents must form a complete traceability chain. First of all, the authenticity of the third-party certificate of origin should be reviewed to ensure that the factory information and cargo model on the certificate of origin fully match the processing certificate of the transit port; secondly, the customs declaration form of the transit port must be marked with "transit goods", and the container number and seal number shall be submitted to the customs for review together with the bill of lading of the port of departure; in case of customs valuation disputes, the purchase contract and invoice of the third-party factory shall be prepared in advance to prove that the goods have real cargo right transfer at the transit port.

In addition, it is forbidden to mark the words "originated in China" on any documents, including shipping marks, packaging, and document remarks, otherwise it will trigger anti-dumping investigation by the customs of the importing country, leading to document deletion and re-declaration or even customs detention.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

The core of transit trade logistics lies in cargo right control and transit node connection. First of all, choose a shipping company that directly reaches the transit port at the port of departure to avoid secondary transit increasing the risk of cargo damage; the transit port should be a port with an exclusive transit cargo yard to ensure that the container replacement operation is completed within 24 hours after the goods arrive at the port, reducing the probability of demurrage; the bill of lading should adopt the "order bill of lading" and endorse it to the third-party company designated by the transit freight forwarder to ensure that the cargo right is controllable in the transit link.

In case of abnormal situations such as container rolling and space explosion, sign a "transit priority guarantee agreement" with the shipping company in advance, and reserve a 1-2 day transit buffer period; at the same time, require the transit freight forwarder to feedback the cargo status every day, including arrival time, container replacement progress, departure time, to ensure synchronization with the delivery time of the import customer.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

The core of transit trade taxation lies in benefit hedging and compliant planning. First of all, evaluate the VAT policy of the transit country, and choose a transit port that allows VAT deferment (such as Singapore), which can avoid paying value-added tax in the transit link in advance and reduce the cost of capital occupation; secondly, reasonably plan the pricing of related party transactions to ensure that the profit of the transit link is in a reasonable range and avoid triggering BEPS (Base Erosion and Profit Shifting) investigation; in addition, if the transit trade involves RMB cross-border payment, the pricing advantage of the CIPS system can be used to lock the foreign exchange purchase rate and hedge the exchange difference risk.

At the same time, all tax documents (including invoices from third-party factories and tax certificates from transit ports) should be retained to ensure that a complete chain can be provided when the tax authority verifies, so as to avoid tax penalties caused by missing documents.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

The core of payment and receipt compliance for transit trade lies in the matching of capital flow and cargo flow. First of all, foreign exchange receipt shall be transferred through a third-party account in the transit country to avoid direct remittance from the importing country account to the domestic account, which will trigger the "abnormal foreign exchange receipt" warning of the foreign exchange administration; secondly, the SWIFT message shall be marked with "transit trade payment" and attached with the transit port bill of lading and certificate of origin number to ensure that the capital flow is consistent with the document flow; if the CIPS system is used for RMB payment, the transit trade payment and receipt filing shall be carried out at the foreign exchange administration in advance, and the estimated transit time, cargo information and counterparty information shall be submitted.

In addition, it is forbidden to use personal accounts to collect and pay transit trade funds, otherwise it will trigger the anti-money laundering investigation of the foreign exchange administration and lead to account freezing.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

The legal core of transit trade lies in risk coverage and legal protection. First of all, sign the Transit Trade Service Agreement with the transit freight forwarder, clearly stipulate the upper limit of demurrage, cargo damage compensation standard, and document compliance responsibility, so as to avoid unclear rights and responsibilities when disputes arise; secondly, sign a supplementary agreement with the import customer to clarify the operation method of transit trade and the exemption clause for delivery delay, so as to avoid customer claims caused by transit abnormalities; in addition, legal due diligence shall be conducted on the authenticity of the third-party certificate of origin, and the third-party factory shall issue the Certificate of Origin Authenticity Guarantee Letter. If the customs detention is caused by the false certificate of origin, the third-party factory shall bear all losses. At the same time, the original copies of all agreements and guarantee letters shall be retained to ensure that a complete evidence chain can be provided when legal disputes arise.

Victor Sun
Victor SunYears of service:5Customer Rating:5.0

Trade Risk Control ManagerStart a Chat

The core of transit trade supply chain lies in cost actuarial calculation and structure optimization. First of all, establish a transit trade cost model, covering all link costs such as freight at the port of departure, container replacement fee at the transit port, third-party document fee, customs clearance fee at the import port, etc., compare the anti-dumping duty cost of direct export, and calculate the income ratio; secondly, optimize the inventory linkage strategy, pre-stock part of the goods in the bonded warehouse of the transit port, shorten the transit time, and improve the order response speed; in addition, the CIF trade term can be converted into the FOB transit port term, and the import customer shall bear the freight and risk after the transit port, so as to reduce their own cost pressure.

At the same time, the logistics cost and policy changes of the transit port shall be evaluated every quarter, and the transit plan shall be adjusted in time to ensure the stability and profitability of the supply chain.

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